Guest Author - Roger Graham VP
Master of Science and Technology in Aviation Safety - UNSW, GradDip Safety Science - UNSW, SPQ - UNSW, CPMAIHS, RSP (Aust), ASSP, Dip Emergency Medicine - EMT
Over the last five years or more there's been a disturbing trend of safety officers appearing out of nowhere claiming to be industry qualified. Some with fraudulent resumes’. Some contractors have gone so far as to claim that a traffic controller or a security guard with a Certificate IV in WHS is legally able to act as an industry safety officer. Unfortunately, Producers are falling for it, at great risk.
It is not illegal to call yourself a safety officer. While the title of a medical doctor, paramedic or lawyer is legally protected, the title of safety officer is not. However, in law, there is a big difference between calling yourself a safety officer and actually being a verifiably qualified safety officer.
Historically, important and dangerous industries such as medicine have successfully sought to make it illegal to call yourself a medical doctor unless you have accepted qualifications and are registered by the appropriate industry body. While other professions which are equally dangerous and important do not have a system in place to identify fraudulent claims of competency. Safety is one of those.
Our industry for a long time has maintained a standard, in fact we were one of the first in the world to do so. However, it appears now that our organising bodies do not feel they are in a position to stand by past endorsements. Mainly because the position of safety officer has evolved into a far more legally fraught and morally difficult responsibility, requiring far more expertise than ever; making the endorsing organisation part of a serious liability chain.
Safe Work and the accompanying acts & regulations understand that not all industries are going to have robust internal oversight, and as a result they have described strict competency requirements in regulations. Workplace health and safety regulations have several clauses that must be met in order for someone to be considered competent. So, while it may be ok to call yourself a safety officer, you still have to meet a reasonable standard of training and experience to legally act as a safety officer. And while a prospective employer might feel confident that there’s some leeway on this subject, just remember that the courts love to debate the grey areas at great expense of time and money to you. And you will not win either way.
Let’s look at the legal definition of competence.
| Work Health and Safety Regulation 2017 - Current version for 1 March 2025 to date (accessed 30 March 2025 at 15:04) Ch1, Pt 1 sect 5 competent person means— (g) for any other case—a person who has acquired through training, qualification or experience the knowledge and skills to carry out the task. |
So, what is a Certificate IV and why it is inadequate without experience and industry training?
A Certificate IV in Workplace Health and Safety (WHS) is a qualification that provides basic knowledge and skills necessary for managing health and safety in the workplace. While it equips learners with essential principles and practices, there are several reasons why it is not adequate on its own for expert consultation purposes.
A Certificate IV is meant for people who have to deal with WHS as an incidental part of their main job. It’s merely an introduction to the system of WHS, an overview representing only a few hours of training and assessment. Alone, it cannot make you expert or professionally competent.
Here are the key points to consider:
1. Depth of Knowledge:
- Limited Specialisation: A Certificate IV in WHS offers only a broad overview of health and safety legislation, risk assessment, and management processes. However, it lacks the depth required to address complex issues that experts often face. Specialised fields—which may include ergonomics, firearms, SFX, tracking vehicles, occupational health psychology, or industry-specific hazards that require further education and training far beyond the Certificate IV level.
- Foundation-Level Skills: The curriculum often focuses on implementation and compliance rather than deep analytical thinking or critical evaluation of complex safety systems, which are crucial for effective consultation.
2. Experience Requirements:
- Practical Experience: While the certificate may require some coursework and practical assignments, it does not require the level of hands-on experience or real-world problem-solving that expert consultants typically possess. Expertise usually comes from years of industry experience and real-world applications of theory.
- Diverse Environments: Effective consultants and safety officers often need to adapt their knowledge and strategies to various environments and industries. Experience in these diverse fields is often gained through more advanced qualifications and various roles in the industry over time.
3. Advanced Qualifications:
- Professional Certifications: Recognised professional qualifications such as those developed by ESA are often necessary for professional and specific industry consultancy roles. These certifications provide rigorous training and assessment and are recognised globally, thereby enhancing credibility as a safety officer/consultant.
- There is Higher Education and Certification: Many expert consultants hold advanced qualifications, such as a Bachelor’s or Master’s degree in Occupational Health and Safety, Safety Science, Environmental Science, or a related field. These programs offer in-depth knowledge and critical skills that go beyond the scope of a Certificate IV. Yet these qualifications have little more than academic value without industry specific experience and mentorship to accompany them. In my expert opinion the mix of experience and academia must be weighted toward experience; being the most important element for industry competency.
4. Complex Problem-Solving Skills:
- Critical Thinking and Analysis: Expert consulting often requires robust analytical skills to identify and evaluate risks, manage crises, and design comprehensive health and safety strategies. The Certificate IV may introduce risk assessment protocols ( most of which are simplistic & outdated), but it does not cultivate the advanced critical thinking and problem-solving capabilities expected of a consultant.
- Tailored Solutions: Safety officers without experience & knowledge will tend to be an obstruction, lacking in workable solutions. They actually do not have the qualifications to interpret and implement work-arounds. They must blindly follow the rules (you can do that yourself!). Experts can create customised safety solutions based on in-depth analysis of organisational culture, workflows, and unique risks. This capability typically requires years of practice and learning that exceed the scope of a Certificate IV qualification.
5. Regulatory Knowledge:
- Legislative Changes: Health and safety regulations are continually evolving. An expert consultant/safety officer must be adept at interpreting and applying current laws, regulations, and standards. A Certificate IV will glance over existing legislation but will not provide a deep understanding of legislative nuances, recent changes, or implications for varying industries.
- Compliance vs. Best Practices: Productions often seek consultants for guidance on achieving not only compliance but also best practices in health and safety management. Expertise in developing proactive strategies and interventions often comes from extensive education and experience way beyond the Certificate IV level.
6. Industry-Specific Knowledge:
- Understanding Unique Risks: Each industry has specific health and safety risks (film and television production, construction, mining, healthcare, etc.), requiring a nuanced understanding of these dynamics. A Certificate IV does not cover the specifics needed for consultation in specialised sectors.
- Emerging Issues: The workplace safety landscape is continually changing, with emerging trends and issues (like psychological health, new technologies, etc.) that require ongoing education and specialisation.
7. Leadership and Influence:
- Stakeholder Engagement: Expert consultants/safety officers are often required to engage with multiple stakeholders, from executives to frontline workers, and to influence organisational culture. Skills in leadership, negotiation, and advanced communication go way beyond what is taught in a Certificate IV program. They can only be gained through a mentorship program.
- Implementation Strategies: Developing strategies for implementing health and safety systems that are effective and sustainable requires a comprehensive understanding of change management and organisational behaviour, areas not covered in the Certificate IV curriculum.
- The Mentor Factor: Experience also fosters mentorship opportunities. Seasoned professionals can guide newcomers, sharing insights and fostering an environment of growth. Mentorships enhance the skills of less experienced individuals while reinforcing the knowledge of mentors, creating a cycle of continuous improvement within the industry.
8. Continuous Professional Development:
- Up-to-Date Knowledge: The field of workplace health and safety is dynamic, with ongoing changes in laws, regulations, and best practices. A Certificate IV will not equip individuals with the knowledge or skills required to stay current with industry developments, making it insufficient for long-term competence.
- Lifelong Learning: Industry competence often requires ongoing education and professional development beyond initial certifications. Employers typically seek professionals who are committed to continuous learning and improvement. Is someone taking short cuts committed to excellence?
Let’s take a look at the other important regulation concerning the hiring of independent consultants such as safety officers. The requirement to exercise “Due Diligence”.
| Work Health and Safety Act 2011 No 10 Current version for 2 March 2025 to date (accessed 30 March 2025 at 15:25) 5) In this section, due diligence includes taking reasonable steps— (a) to acquire and keep up-to-date knowledge of work health and safety matters, and (b) to gain an understanding of the nature of the operations of the business or undertaking of the person conducting the business or undertaking and generally of the hazards and risks associated with those operations, and (c) to ensure that the person conducting the business or undertaking has available for use, and uses, appropriate resources and processes to eliminate or minimise risks to health and safety from work carried out as part of the conduct of the business or undertaking, and (d) to ensure that the person conducting the business or undertaking has appropriate processes for receiving and considering information regarding incidents, hazards and risks and responding in a timely way to that information, and (e) to ensure that the person conducting the business or undertaking has, and implements, processes for complying with any duty or obligation of the person conducting the business or undertaking under this Act, and Example. For the purposes of paragraph (e), the duties or obligations under this Act of a person conducting a business or undertaking may include— - reporting notifiable incidents, - consulting with workers, - ensuring compliance with notices issued under this Act, - ensuring the provision of training and instruction to workers about work health and safety, - ensuring that health and safety representatives receive their entitlements to training. |
Employers must continually and comprehensively make sure that workers, volunteers and visitors are kept safe in the workplace. This ‘due diligence requires the employer to ensure that people they hire are competent to the job that they are required to perform. Ultimately, if your safety oversight is not of a professional standard then you are open to accidents and incidents and all of the litigation that will follow.
Conclusion:
Employers should seek individuals who possess a deeper understanding of industry-specific risks, extensive hands-on experience, and the ability to navigate complex health and safety challenges effectively. Consequently, individuals aiming for a competent role in health and safety should be pursuing further education, specialised certifications, and gaining relevant experience in their chosen industry. This is what ESA is aiming to provide.
While a Certificate IV in WHS provides a valuable starting point for understanding workplace health and safety systems & principles, it is nowhere near sufficient for industry specific or expert level consultation. Consultants and safety officers are expected to possess a blend of advanced education, extensive experience, and specialised skills that facilitate in-depth analysis, strategic planning, and effective communication within complex organisational settings. For those aspiring to become safety officers, pursuing further education and certifications while gaining practical experience in the field is essential for providing clients with the best form of safety protections from incidents and liability exposure.
In short, a mentorship coupled with an industry specific academic training program over a reasonable period of time, is the only way to be a verifiable industry specific safety officer/consultant.
A parting note:
And after an incident… would you want to rely on a safety officer (in name only), to go to court as your expert witness. I think not!
AUTHOR: ROGER GRAHAM VP